Large crowds / widlerness
I regularly listen to FM radio using my mobile phone; it much works pretty much everywhere, anytime.
If I'm competing with thousands of others for the local tower's capacity in/around a football stadium on match day I doubt that I'd get the throughput to listen to a live Internet radio stream; if I'm in the wilderness, there is no internet radio. This is why my personal minimum spec for a phone includes FM radio.
Other negatives for streaming include the required data allowances and the massive latency of the broadcast - listen to streamed football commentary and your 'latest scores' app will notify you of a goal/event way before you hear it happen on the 'live' broadcast. Also, I'd be very surprised if streaming used less power than FM